1999 (2) TMI 117

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..... f gray fabrics on job work basis. On the strength of information given by the Merchant manufacturer, they filed D-3 declaration and also classification list showing composition of 55% cotton and 45% polyester. These gray goods were processed under lot numbers 1271 and 1272. Samples from these lots were drawn on 18-12-1987. The test results dated 4-8-1988 showed predominance of synthetic fibres in .....

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..... regards the point of limitation, which I find not to be relevant. However, in order to invoke the extended period, the suppression etc. on part of the assessees has to be proved by the department. Conversely, where the department had knowledge of a wrong declaration made by the assessee, the extended period cannot be invoked. In this case, the wrong classification was known to the department as s .....

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